OPPOSING VIEWS

A Liberal commitment to evidence-based decision-making requires that we respectfully study evidence based perspectives that disagree with ours.

Below, reproduced in full is a summary of the case supporting the current policy position of Canada’s PMRA, as stated by Terry Daynard in a Oct. 15th posting to his blog site. We have responded to this perspective at the bottom of Daynard's argument.

Source: (http://tdaynard.com/)

1. Despite an effective campaign by a partnership of the Ontario Bee Association and the Sierra Club of Canada, seeking a ban on neonic usage in Ontario, science and statistics do not support their position.

2. Statistics Canada data show that the number of honey bee colonies was up, not down, in both Ontario and Canada in 2012. Anecdotal reports say this trend continues in 2013.

3. While some beekeepers have experienced excessive losses in recent years, most other beekeepers have not, including many with hives immediately adjacent to treated corn fields.

4. Despite claims to the contrary, there has been no shortage of pollinator bees for horticultural crop producers across Ontario. By contrast, there are reports of beekeepers seeking crops for bees to forage/pollinate. Ontario continues to send many thousands of hives to Atlantic Canada each year for blueberry pollination. The quality of the shipped bees has been unusually good in 2012 and 2013.

5. In the Prairie Provinces where 80% of Canadian bee/honey production occurs and where neonic usage is also much higher than in Ontario (canola and corn seed treatment), there is no linkage between neonics and bee deaths.

6. The Canadian Honey Council, representing bee keepers all across Canada, actively opposes the request by the board of the Ontario Beekeepers Association for a ban on neonic usage. They consider that the harm to other farmers would be substantial, with no notable change in bee mortality.

7. Overwinter bee death percentages vary widely from year to year. Recent Ontario numbers are not that different from historical patterns. The percent is highly dependent on management. Low hive numbers in spring are easily adjusted for by hive splitting and other normal beekeeper practices.

8. Bees are always dying in large numbers. An average of about 2000 dies per hive each day, given their short life span. Overwinter hive sizes are almost 90% lower than during mid season.

9. The real cause of increased bee mortality for some beekeepers in recent years is the arrival of varroa mites. These mites are huge, relative to the size of a bee. They suck blood (or its insect counterpart) out of bees and also inject deadly viruses into the bees. It’s akin to malaria spread by mosquitoes.

10. Varroa mites and viruses are deadly to bees but another problem is that the chemical controls can be just as deadly. These materials must be applied just right. Casual bee management practices, which worked well before varroa arrived, mean excessive bee mortality now. And quality bee/varroa management keeps changing as the mite develops resistance to formerly effective miticides.

11. A new miticide first registered for usage in Canada in early 2012 could be a major problem. It’s called Mite Away Quick Strips (MAQS) and is based on the toxic formic acid. It is produced and widely used in Ontario but not in Western Canada. It is especially toxic at higher temperatures – not recommended for use above 82F in Northern Ohio, and Ontario had many days with higher temperatures in May 2012 when some Ontario beekeepers reported high losses.

12. Ontario bees have also been affected by a recently arrived strain/species of a serious fungal disease, Nosema. The interactions between this disease, fungicide treatments, and the complications provided by varroa and viruses, and their chemical controls, are not well understood.

13. Other stresses can weaken bees, especially if bees are already weakened by varroa, viruses, diseases and mites. These include inadequate bee nutrition (quantity and quality) during periods when the nectar and pollen supply is inadequate, and transport over long distances.

14. Successful, careful beekeepers in Ontario say that skilled bee/varroa management coupled with quality hygiene (the same principles which apply for livestock and poultry producers) is what is needed to ensure hive survival and productivity.

15. Dust from corn seed treatments may be a factor, on windy days with certain brands of corn planters and when talc powder is added to the seed. Bees which are already very weak for reasons listed above may be vulnerable. Efforts are underway in the corn industry to alter the seed treatments and planter design (or the choice of equipment purchase). However, correcting this problem will not likely reduce the high mortality for some beekeepers if they don’t address more fundamental management problems.

16. A shift in the position of the Ontario Beekeepers Association, from one that “the problem is corn seed treatments in spring time,” to one that “neonics are everywhere in air, soil, and water and must be banned” actually weakens their case, for it further raises the question of why this is not the problem in Western Canada where neonic usage is so much greater.

17. If the Government of Ontario were to introduce a neonic ban as a key solution to the so-called bee mortality problem, it risks experiencing even greater ire in days ahead, i.e., when some vocal beekeepers find that the problem is just as bad as before and when corn farmers experience serious losses due to damage caused by insects now controlled by neonic seed treatments. There is also a high probability that many corn farmers would switch to the use of other insecticides much more harmful to themselves and the environment. Finally, the demand for a neonic ban could extend to horticultural farmers who are highly dependent on foliar spray applications of neonics for insect control.

A Liberal Policy Response

As articulated above, (and we know of no voice more respected, diligent or articulate in support of the case to leave neonicotinoid registration status untouched) the alternative to our policy perspective can be summarized on the basis of the following considerations listed in order of emphasis in the commentary above.

• Scientific uncertainty around the causal relationship between colony collapse and application of neonicoitinoids

• Identification of other factors involved in colony collapse

• Hope for harm reduction through modification of seeding equipment and seeding protocols

• Human and environmental safety of alternatives

To these points we respectfully respond with the following commentary:

• Scientific uncertainty around the causal relationship between colony collapse and application of neonicotinoids

This consideration is less prominent as a defense of these insecticides than it was several years ago, as more evidence comes to light. Daynard’s reporting indicates that Canada’s PMRA in their recent review does identify a direct causal link between agricultural use of neonicotinoids and mass bee death. The debate around causality has shifted to a question of seasonality and exposure rates. The thrust of this argument is that exposure rates are highest during spring planting season, and that the exposure rates caused by systemic translocation of the seed-coat insecticide to plant flowers are below the level required to cause toxicity in bees. New light has been cast on that issue by a new study published Oct. 21, 2013 in the American Academy of Science.

• Identification of alternative factors involved in colony collapse

This consideration is the primary thrust of Mr. Daynard’s commentary. We take at face value the validity of research that points to multiple causes involved in mass bee die-offs. However, we feel it is important to note that the study published on Oct. 21, 2013 in the American Academy of Science shows that these causes are not competing explanations, but a system of effects working together to create colony collapse. The implication is that while varroa mites, and in particular the virus they spread in colonies is the ultimate killer of the bees, non-toxic levels of exposure to neoniciotinoids is associated with impaired immune response to the virus. This means trace exposure to neonicotinoids caused by translocation to plant flowers stands as a plausible root cause of colony collapse, notwithstanding the existence of other factors and notwithstanding the sub-lethal exposure level. (http://arstechnica.com/science/2013/10/an-insecticide-infection-connection-in-bee-colony-collapses/ )

• Hope for harm reduction through modification of seeding equipment and seeding protocols

The PMRA policy review and recommendations pre-date the study published in Oct. 2013, and focus on the acute toxicity exposure conditions surrounding planting season. These policy recommendations fail to address the systemic translocation to crop flowers, the immune-system impairment associated with sub-toxic exposure levels, and the system of effects when neonicotinoid exposure combines with exposure to varroa mites and the lethal virus they carry into colonies.

• Human and environmental safety of alternatives

In our view, this last point, which receives only one sentence, buried in point #17 in Mr Daynard’s summary analysis is the most troubling counterargument to a moratorium:

“There is also a high probability that many corn farmers would switch to the use of other insecticides much more harmful to themselves and the environment.”

In the short term, this is a logical proposition. However, if Mr. Daynard believes the alternative agricultural chemicals that are currently registered for the same purpose should not be, he does not go so far as to say so. The policy question is whether we are prepared to indefinitely accept the status quo on the basis of this threat – at the expense of wild and domestic pollinators. Or do we act now, on the basis of accumulated evidence, and send a stronger policy signal to the agrichemical industry to accelerate the development of alternative seed treatments that do not trade off human health and safety for the health of wild and domestic pollinators.